## Facts

- Charles C. Rouse was found not guilty by reason of insanity on a District of Columbia misdemeanor charge of carrying a dangerous weapon, punishable by up to one year.
- After the acquittal, the court committed Rouse to Saint Elizabeths Hospital under D.C. Code § 24-301(d).
- Rouse remained confined for about four years—well beyond the one-year maximum sentence for the charged offense.
- Rouse petitioned for habeas corpus, alleging continued confinement was unlawful because (1) treatment for the condition leading to the insanity acquittal was no longer necessary and (2) the hospital had provided no psychiatric treatment for approximately six to seven months.
- The district court held a hearing, denied relief, and declined to consider the adequacy of treatment, limiting its inquiry to whether Rouse had “recovered his sanity.”

## Issues

1. Whether an insanity acquittee involuntarily committed to a public mental hospital has a statutory right to adequate treatment.
2. Whether denial of adequate treatment is cognizable in a habeas corpus proceeding challenging continued confinement.
3. Whether the district court erred by refusing to consider the adequacy of treatment and limiting review to sanity recovery.

## Decision

- The court of appeals reversed and remanded.
- It held that District of Columbia law provides a statutory right to treatment for involuntarily committed patients, including those committed under D.C. Code § 24-301.
- It held that an alleged denial of that right is cognizable in habeas corpus because the legality of confinement depends on the therapeutic justification for commitment.
- It ruled the district court erred by refusing to consider whether Rouse was receiving adequate treatment.
- It ordered further proceedings to determine whether Rouse was receiving adequate treatment and, if not, the reasons and circumstances for the deficiency.

## Legal Principles

- Involuntary hospitalization is justified as treatment rather than punishment; confinement that becomes purely custodial risks becoming unlawful.
- District of Columbia statutes governing public mental hospitals require care and treatment consistent with current/accepted medical standards, creating an enforceable right to minimally adequate treatment.
- “Treatment” includes more than occasional psychiatrist contact; it includes therapeutic activities and staff interactions intended to improve or alleviate the patient’s condition, not mere warehousing.
- Habeas corpus may be used to challenge continued confinement when the state fails to provide the treatment that supplies the legal basis for involuntary detention.
- When commitment follows an insanity acquittal under a relatively summary procedure, continued confinement without treatment raises serious due process concerns, reinforcing the need for judicial review of treatment adequacy.

## Conclusion

The court recognized a statutory right to adequate treatment for persons committed after an insanity acquittal and held that claimed denial of treatment can be litigated in habeas corpus; it remanded for fact-finding on whether the hospital provided treatment meeting accepted medical standards and, if not, why.


Rouse v. Cameron, 373 F.2d 451 (D.C. Cir. 1967)